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C. Peter Magrath, who discovered the exchange while researching ''Morrison C. Waite: The Triumph of Character'', writes "In other words, to the Reporter fell the decision which enshrined the declaration in the ''United States Reports''...had Davis left it out, ''Santa Clara County v. Southern Pac[ific] R[ailroad] Co.'' would have been lost to history among thousands of uninteresting tax cases."<ref>C. Peter McGrath, ''Morrison R. Waite: The Triumph of Character'' (New York: Macmillan, 1963), p.117</ref>
C. Peter Magrath, who discovered the exchange while researching ''Morrison C. Waite: The Triumph of Character'', writes "In other words, to the Reporter fell the decision which enshrined the declaration in the ''United States Reports''...had Davis left it out, ''Santa Clara County v. Southern Pac[ific] R[ailroad] Co.'' would have been lost to history among thousands of uninteresting tax cases."<ref>C. Peter McGrath, ''Morrison R. Waite: The Triumph of Character'' (New York: Macmillan, 1963), p.117</ref>

Author Jack Beatty wrote about the lingering questions as to how the reporter's note reflected a quotation that was absent from the opinion itself.
<blockquote>
Why did the chief justice issue his dictum? Why did he leave it up to Davis to include it in the headnotes? After Waite told him that the Court 'acoided' the issue of corporate personhood, why ''did'' Davis include it? Why, indeed, did he begin his headnote with it? The opinion made plain that the Court did not decide the corporate personality issue and the subsidiary equal protection issue.<ref>Beatty, ''Age of Betrayal'', p. 173
</blockquote>


== Decision ==
== Decision ==

Revision as of 01:24, 20 September 2009

Santa Clara County v. Southern Pacific Railroad
Supreme Court of the United States
Argued January 26–29, 1886
Decided May 10, 1886
Full case nameSanta Clara County v. Southern Pacific Railroad Company
Citations118 U.S. 394 (more)
Holding
The railroad corporations are persons with the intent of the Fourteenth Amendment to the U.S. Constitution.
Court membership
Chief Justice
Morrison Waite
Associate Justices
Samuel F. Miller · Stephen J. Field
Joseph P. Bradley · John M. Harlan
William B. Woods · Stanley Matthews
Horace Gray · Samuel Blatchford
Case opinion
MajorityHarlan, joined by Unanimous court
Laws applied
14 Stat. 292, §§ 1, 2, 3, 11, 18 (an Act of 1866 giving special privileges to the Atlantic and Pacific Railway Corporation)

Santa Clara County v. Southern Pacific Railroad Company, 118 U.S. 394 (1886) was a United States Supreme Court case dealing with taxation of railroad properties. The case is most notable for the obiter dictum statement that juristic persons are entitled to protection under the Fourteenth Amendment.

For its opinion, the Court consolidated three separate cases: Santa Clara County v. Southern Pacific Railroad Company, California v. Central Pacific Railroad Company, and California v. Southern Pacific Railroad Company.

At the California Constitutional Convention of 1878-79, the state legislature drew up a new constitution that denied railroads "the right to deduct the amount of their debts [i.e., mortgages] from the taxable value of their property, a right which was given to individuals." [1] Southern Pacific Railroad Company refused to pay taxes under these new changes. The taxpaying railroads challenged this law, based on a conflicting federal statute of 1866 which gave them privileges inconsistent with state taxation (14 Stat. 292, §§ 1, 2, 3, 11, 18).

San Mateo, along with neighboring counties filed suit against the railroads to try and recoup the massive shortage of tax revenue stemming from Southern Pacific's refusal to pay. After hearing arguments in San Mateo County v. Southern Pacific Railroad Company, the California state Supreme Court sided with the county. Using the Jurisdiction and Removal Act of 1875, a law created so black litigants could surpass hostile southern state courts if they were denied justice, Southern Pacific was able to appeal all the way to the U.S. Supreme Court.[2]

A passing remark

The decisions reached by the Supreme Court are promulgated to the legal community by way of books called United States Reports. Preceding every case entry is what's known as a headnote, a short summary where a court reporter summarizes the opinion as well as outlining the main facts and arguments. For example, in U.S. v. Detroit Timber and Lumber (1905), a headnote is defined as "not the work of the Court, but are simply the work of the Reporter, giving his understanding of the decision, prepared for the convenience of the profession."[3]

The court reporter, J.C. Bancroft Davis, who was a former Railroad president, wrote the following as part of the headnote for the case:

"The court does not wish to hear argument on the question whether the provision in the Fourteenth Amendment to the Constitution, which forbids a State to deny to any person within its jurisdiction the equal protection of the laws, applies to these corporations. We are all of the opinion that it does."[4]

The most interesting aspect of this quote is that it is absent from the actual opinion itself. Before publication, Davis wrote a letter to Chief Justice Morrison Waite, dated May 26, 1886, to make sure his headnote was correct:

Dear Chief Justice,

I have a memorandum in the California Cases Santa Clara County v. Southern Pacific %c As follows. In opening the Court stated that it did not wish to hear argument on the question whether the Fourteenth Amendment applies to such corporations as are parties in these susits. All the Judges were of the opinion that it does.[5]

Waite replied:

I think your mem. in the California Railrad Tax cases expresses with sufficient accuracy what was said before the argument began. I leave it with you to determine whether anything need be said about it in the report inasmuch as we avoided meeting the constitutional question in the decision.[6]

C. Peter Magrath, who discovered the exchange while researching Morrison C. Waite: The Triumph of Character, writes "In other words, to the Reporter fell the decision which enshrined the declaration in the United States Reports...had Davis left it out, Santa Clara County v. Southern Pac[ific] R[ailroad] Co. would have been lost to history among thousands of uninteresting tax cases."[7]

Author Jack Beatty wrote about the lingering questions as to how the reporter's note reflected a quotation that was absent from the opinion itself.

Why did the chief justice issue his dictum? Why did he leave it up to Davis to include it in the headnotes? After Waite told him that the Court 'acoided' the issue of corporate personhood, why did Davis include it? Why, indeed, did he begin his headnote with it? The opinion made plain that the Court did not decide the corporate personality issue and the subsidiary equal protection issue.Cite error: A <ref> tag is missing the closing </ref> (see the help page).

The Supreme Court never reached the equal protection claims. Nonetheless, this case is sometimes incorrectly cited as holding that corporations, as juristic persons, are protected by the Fourteenth Amendment.[8]

Impact

As such, it did not technically - in the view of most legal historians - have any legal precedential value.[9] However, the Supreme Court is not required by Constitution or even precedent to limit its rulings to written statements.

Justice William O. Douglas wrote in 1949, "the Santa Clara case becomes one of the most momentous of all our decisions.. Corporations were now armed with constitutional prerogatives."

See also

References

  1. ^ Carl Brent Swisher, "Motivation and Political Technique" in The California Constitutional Convention, 1878-1879 (New York: Da Capo, 1969), p. 78
  2. ^ R. Hal Williams, The Democratic Party and California Politics, 1880-1896 (Stanford: Stanford University Press, 1973), pp. 34-36
  3. ^ http://supreme.justia.com/us/200/321/
  4. ^ 118 U.S. 394 (1886) - According to the official court Syllabus in the United States Reports
  5. ^ Jack Beatty, Age of Betrayal: The Triumph of Money in America, 1865-1900
  6. ^ Ibid.
  7. ^ C. Peter McGrath, Morrison R. Waite: The Triumph of Character (New York: Macmillan, 1963), p.117
  8. ^ When Is a Corporation Like a Freed Slave?
  9. ^ Thomas Van Flein. "Headnotes and the Course of History." The Alaska Bar Rag. May/June, 2003 (27 AK Bar Rag 2)
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